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-2- <br />future development of Colorado River water that Colorado entered into the Colorado River and <br />Upper Colorado River Basin Compacts. <br />Given this relationship with the Colorado River, Colorado clearly has a substantial interest in the <br />efficient management and wise administration of the Colorado River System and System <br />reservoirs. The Colorado River System and its reservoirs must be administered and managed in a <br />manner that meets the needs of the Colorado River basin states without jeopardizing Colorado's <br />significant, legally protected rights to the waters of the Colorado River, or compromising its <br />ability to serve the present uses and future needs of Colorado citizens. It is in the interest of <br />protecting the rights and needs of its citizens that Colorado submits these Comments. <br />The State of Colorado's Comments consist of two parts. First, Colorado joins in the Basin <br />States' Combined Comments, Recommendations, and Proposed Guidelines (the "Basin States' <br />Comments"), submitted under separate cover. Colorado strongly believes that the Basin States' <br />Alternative, as described in the DEIS and clarified and implemented by the Basin States' <br />Comments, sets forth the appropriate mechanism for interim management of the Colorado River <br />System through 2025. As is more fully explained in the Basin States' Comments, the Basin <br />States' Alternative best addresses the issues raised by the proposed federal action (the "Action"), <br />as described in the DEIS and the Bureau's March 2006 Scoping Summary Report. Accordingly, <br />Colorado joins the Basin States in requesting that you adopt the Basin States' Alternative, as <br />implemented through the Basin States' Proposed Guidelines, as the preferred alternative in the <br />Final Environmental Impact Statement and Record of Decision. <br />Second, the State of Colorado submits the following general Comments to the DEIS to address <br />concerns specific to Colorado. These individual State Comments are not intended to suggest any <br />disagreement with the Basin States' Comments, or to call into question Colorado's support for <br />the Basin States' Alternative. Rather, they are intended to identify and suggest means of <br />addressing issues of unique interest to Colorado. <br />These Comments are as follows: <br />Affected Geographic Region. The DEIS defines the geographic region affected by the <br />Action as Lake Powell and the River below Lake Powell. The DEIS analyzes the effects of <br />the Action only within this geographic region.Z However, decisions made regarding <br />management of Lakes Mead and Powell also could potentially affect the geographic region <br />upstream of Lake Powell after 2025. Decreased or increased storage in Lake Powell could <br />affect storage levels in other Upper Basin reservoirs, and thus increase or decrease the risk <br />that Upper Division States would have to curtail their uses of Colorado River water in order <br />to satisfy the Upper Basin's obligations under Article III(d) of the Colorado River Compact. <br />In addition, curtailment in the Upper Division or shortages in the Lower Division could <br />potentially impose cumulative impacts on other geographic regions. <br />Notwithstanding these facts, because Colorado believes it unlikely that Upper Division <br />curtailment will be necessary during the interim period of 2008 through 2025, Colorado does <br />not, at this time, object to the limited description of the affected geographic region set forth <br />in the DEIS; provided, however, that said description is understood to be applicable only to <br />2 For example, the DEIS describes the affected geographic region as Lake Powell and the Lower Basin at pages <br />including, but not necessarily limited to: p. 1-7, lines 5-7; p. 3-3, lines 1-24; p. 4-81, lines 37-39. <br />Flood Protection • Water Project Planning and Finance • Stream and Lake Protection <br />Water Supply Protection • Conservation Planning <br />